MADANBHAI DAYARAM RAMWANI,AHMEDABAD vs. ITO WARD 3(1)(2), AHMEDABAD

ITA 2607/AHD/2026Status: DisposedITAT Ahmedabad08 September 2026AY 2018-194 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal set aside the matter to the Jurisdictional AO to verify if the income was already offered as business income. If confirmed, the double addition made by the CPC needs to be deleted.

What were the facts?

The assessee offered interest and remuneration from firms as business income. The CPC processed the return and made an adjustment for salary and other income, leading to alleged double taxation. The assessee's rectification application was rejected, and the CIT(A) dismissed the appeal.

What were the issues?

Whether the adjustment made by the CPC during processing resulted in double taxation of income already offered as business income, and whether the rejection of the rectification application was justified.

Which sections of the Income-tax Act were involved?

Section 154,Section 143(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH, AHMEDABAD

Before: SHRI NARENDRA PRASAD SINHA & SHRI SANJAY KUMAR

For Appellant: Shri Sanjay Rohera, CA
For Respondent: Shri Amit Pratap Singh, SR-DR
Hearing: 31.08.2026Pronounced: 08.09.2026

PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER:

This appeal is filed by the Assessee against the order of National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “CIT(A)”] dated 31.10.2025 for the Assessment Years (A.Y.) 2018-19 in the proceeding u/s 154 of the Income Tax Act [hereinafter referred as “the Act”].

2.

There was delay of 199 days in filing of this appeal. The assessee has filed an affidavit explaining the reason for delay. It has been submitted that the assessee is a senior citizen and not conversant with operating e- mail account. That the order of the Ld. CIT(A) was received on the e-mail Madanbhai Dayaram Ramwanil Vs ITO, AY- 2018-19 2 addre

The order continues below.

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